Tax

Showing the latest top articles for this topic.
24 hours 3 days 1 week 1 month 3 months
UN committee to draft model tax treaty provisions addressing digital economy, transfer pricing manual updates approved
mnetax.com Jul 9, 2020
The UN Committee of Experts on International Cooperation in Tax Matters, at its 20th session, agreed to consider adding new provisions addressing the taxation of the digital economy to the UN Model Double Taxation Convention between Developed and...
New OECD country-by-country reporting statistics offer insight into multinational group tax avoidance behavior
mnetax.com Jul 9, 2020
The OECD on July 9 provided data on no less than 4,000 multinational enterprise groups headquartered in 26 jurisdictions, operating across more than 100 jurisdictions worldwide. This is an important development in terms of data on multinational...
New Saudi Arabia tax guidance addresses mutual agreement procedure
mnetax.com Jul 8, 2020
Saudi Arabia’s General Authority of Zakat and Tax (GAZT), on June 9, published new guidance on making requests under the mutual agreement procedure (MAP) in tax treaties. The guidelines aim to set out the process through which taxpayers may resolve...
OECD publishes model rules for tax reporting by gig economy platform operators
mnetax.com Jul 8, 2020
The Netherlands' new DAC6 requirements: what multinationals need to know
mnetax.com Jul 8, 2020
The Netherlands, on 29 June, published long-awaited guidance on its decree implementing Council Directive 2018/822, better known as the DAC6 directive. Multinationals with European Union operations need to be aware of the DAC6 reporting...
EU to launch tax observatory
mnetax.com Jul 8, 2020
The EU’s awareness of the relevance of tax policy is clear. On 6 July, the European Commission called for proposals for the creation of an EU tax observatory. This follows the adoption of the Commission Decision on the financing of the preparatory...
Netherlands announces new policies for resolving cross-border tax disputes
mnetax.com Jul 7, 2020
The Netherlands government, on June 22, announced new policies regarding the mutual agreement procedures (MAPs) and arbitration procedures in its tax treaties. Both provisions provide mechanisms for resolving cross border tax disputes. The new MAP...
Nigeria clarifies new tax on nonresident digital businesses
mnetax.com Jul 6, 2020
On 29 May, Nigeria’s Minister of Finance issued an order describing when a digital business operated by a nonresident company is deemed to have a significant economic presence in Nigeria and is thus subject to tax. New Companies Income Tax Order...
Denmark Supreme Court rules in favor of Adecco in landmark transfer pricing decision
mnetax.com Jul 2, 2020
Denmark’s Supreme Court on 25 June delivered a significant blow to the Danish Revenue, ruling in favor of Danish company, Adecco, and its Swiss parent company in a dispute involving the deductibility of royalties and the sufficiency of transfer...
Germany announces tax policy goals for Council of the EU Presidency
mnetax.com Jul 2, 2020
On 1 July, Germany disclosed its ambitious goals for its Presidency of the Council of the European Union in its programme“ Together for Europe’s recovery,” including its objectives in the area of tax cooperation. The EU is following the OECD tax...
Poland poised to launch new corporate income tax regime
mnetax.com Jun 29, 2020
It’s going to be a very hot summer this year in Poland as the government has announced that it will introduce the so-called Estonian solution into Poland’s corporate income tax system. The plan is for the new law to enter into force from 2021. The...
EU Council agrees to extend DAC6 reporting, financial account reporting deadlines
mnetax.com Jun 25, 2020
The EU Council today adopted an amending directive giving EU member states the option to delay by six months the time for filing and exchanging information to meet mandatory disclosure requirements for intermediaries and other taxpayers under the...
Australia transfer pricing guidance addresses COVID-19 impact
mnetax.com Jun 25, 2020
On 19 June, the Australian Taxation Office published high-level guidance on the impact of COVID-19 on transfer pricing. This guidance applies to businesses economically affected by COVID-19, and relates to the preparation of transfer pricing...
US Supreme Court lets Altera decision stand: implications for cost sharing and stock options
mnetax.com Jun 23, 2020
The US Supreme Court on Monday announced that it would not review the Ninth Circuit panel decision in the Altera case. Thus, the Supreme Court left standing a June 7, 2019, Ninth Circuit decision that upheld the validity of US cost sharing...
The OECD’s “no Plan B” approach on digital taxation backfires
mnetax.com Jun 22, 2020
As reported by major newspapers last week, the US has announced its withdrawal from the global digital tax talks. In a letter written by US Treasury Secretary Steven Mnuchin to the European finance ministers, Mnuchin explained that from the...
EU Parliament creates permanent tax subcommittee
mnetax.com Jun 22, 2020
In a welcome move, the European Parliament, in its plenary session on 18 June for the first time approved the creation of a permanent subcommittee on tax matters. Made up of 30 members, the new subcommittee will investigate financial crimes in...
Transfer prices based on EBITDA, not EBIT
mnetax.com Jun 18, 2020
In applying the comparable profits method (CPM) in the US or the “transactional” net margin method (TNMM) in other OECD countries, many transfer pricing analysts assume that the depreciation rate of property, plant, and equipment is the same among...
Updated transfer pricing guidelines in Saudi Arabia
mnetax.com Jun 17, 2020
Saudi Arabia’s General Authority of Zakat and Tax (GAZT) on June 1 issued updated transfer pricing guidelines, providing clarification in several key areas, particularly in relation to documentation requirements and intangibles. It is imperative...
Norway Supreme Court rules in favor of Shell subsidiary in transfer pricing dispute
mnetax.com Jun 17, 2020
On 28 May the Norwegian Supreme Court issued a ruling in a transfer pricing case between the Shell group’s Norway subsidiary, A/S Norske Shell, and the Norwegian oil taxation office. The case covered the 2007 to 2012 fiscal years and related to the...
Italy clarifies VAT reporting obligations of online marketplaces
mnetax.com Jun 16, 2020
On 1 June, the Italian Revenue Agency released new guidance (Circulare no. 13/E) clarifying the VAT reporting obligations of online platforms that facilitate remote (or distance) sales. The Italian Revenue Agency noted that under Italy’s new VAT...
The Puma Nordic and Columbia Sportswear transfer pricing cases and the limits of the TNMM
mnetax.com Jun 15, 2020
In their February 11 MNE Tax article, Erik Koponen and Madeleine Thörning analyze a successful challenge by the Swedish tax agency with respect to the transfer pricing between Puma SE and its Swedish distribution affiliate Puma Nordic AB. The...
View more